A. The Plaintiff, a special purpose company established pursuant to the Asset-Backed Securitization Act on June 8, 201, acquired securitization assets in KRW 1,13.9 billion from a national bank, the asset holder of which, on June 28, 201, the Plaintiff acquired at KRW 1,13.9 billion, securitization assets including loan claims secured by land and buildings on the ground, including land and buildings on the surface supervision of 4-16 in the east-si, Kimhae-si, Kimhae-si, the asset holder.

B. In order to recover the above loan claims, the Plaintiff directly participated in the auction procedure of the instant real estate and paid in full the sale price on December 28, 201 upon receiving the decision to permit sale on November 7, 201, and subsequently reported and paid acquisition tax, local education tax, and special rural development tax, calculated by reducing 50/100 of the tax amount by reducing and exempting the acquisition tax, local education tax, and special rural development tax pursuant to Articles 120(1)12 and 119(1)13 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010; hereinafter “former Act”) with respect to the instant real estate as the tax base.

C. On May 12, 2013, the Defendant deemed that the acquisition of the instant real estate does not fall under those subject to reduction or exemption of acquisition tax, and imposed acquisition tax on the Plaintiff KRW 26,628,00, local education tax, KRW 2,462,80, and special rural development tax, KRW 1,331,40, and KRW 30,42,200 (including additional tax) on the Plaintiff.

(hereinafter “Disposition of this case”). [Grounds for recognition] The Disposition of this case is without dispute; Gap evidence 1; Eul evidence 1 to 3 (including branch numbers) and the purport of the whole pleadings.

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) Allied Asset Management Co., Ltd., which established the Plaintiff in violation of the principle of trust protection (hereinafter “Allied Asset Management”).

Even if the new law is applied from the Seoul Special Metropolitan City Treasury Tax Department, a special purpose company acquires the relevant real estate by responding to an auction in the course of managing and operating the right to collateral on the basis of the claim acquired from the originator.